GDPR and UK GDPR

This notice is for individuals in the European Economic Area, the United Kingdom, and Switzerland. It supplements the Privacy Policy and Cookie Policy and the Legal Notices page. It explains how the publisher and operator of Twice Daily Wire (“Twice Daily Wire,” “Wire”) complies with Regulation (EU) 2016/679 (the “GDPR”), the UK GDPR, and the Swiss Federal Act on Data Protection, in each case as applicable. If this notice conflicts with the Privacy Policy as to such an individual, this notice controls.

Wire is a U.S.-based news-gathering and aggregation brief. We offer the Service to readers worldwide, including in the Union, and therefore apply this notice where the GDPR’s territorial scope in Article 3 is engaged.

Wire is the controller of personal data processed in connection with the Service. Contact: privacy@wire-brief.com.

We have not appointed a data protection officer because we are not required to do so under GDPR Article 37: we are not a public authority, our core activities do not consist of large-scale regular and systematic monitoring of data subjects, and our core activities do not consist of large-scale processing of special-category data or data relating to criminal convictions. If that assessment changes, we will appoint a DPO and publish the contact details here.

We have not yet appointed an Article 27 representative in the Union or a UK GDPR representative. Where such an appointment is required, we will designate a representative and publish the name and contact details on this page. Until then, you may exercise your rights by writing to privacy@wire-brief.com.

Because the Service has no reader accounts, the personal data we process is limited:

• Technical data: IP address, approximate location derived from IP, user-agent, requested URL, timestamps, and diagnostic codes, generated when you load a page.
• On-device navigation state: desk filter and search query held in session storage for the length of a visit, and Light / Dark / Auto appearance held in local storage if you set it.
• Correspondence data: if you email us, the contents of your message and the metadata of that email.
• We do not create a persistent marketing profile, and we do not process special-category data about readers as a matter of course. News items in the brief may refer to public events; that is journalistic content, not a file about you.

Our legitimate interests are: operating a non-account news brief for a general audience; keeping that brief secure; and defending the Service. We have considered the impact on readers, the limited data involved, and the fact that the Service can be used without creating an identity. You may object as described below.

We do not engage in automated decision-making that produces legal or similarly significant effects about you, including profiling of that kind (GDPR Article 22).

Subject to the conditions and exceptions in the GDPR and UK GDPR, you have the right to:

• Access — obtain confirmation of whether we process your personal data and receive a copy (Art. 15).
• Rectification — have inaccurate data corrected and incomplete data completed (Art. 16).
• Erasure — obtain erasure in the cases listed in Art. 17, including when the data are no longer necessary or you withdraw consent and no other basis remains.
• Restriction — obtain restriction of processing in the cases listed in Art. 18.
• Portability — receive data you provided to us on the basis of consent or contract, in a structured, commonly used, machine-readable format, and transmit those data to another controller where technically feasible (Art. 20). Given that we keep little reader data, this right may apply mainly to correspondence you sent us.
• Object — object at any time, on grounds relating to your particular situation, to processing based on legitimate interests (Art. 21). We will stop unless we demonstrate compelling legitimate grounds that override your interests, or the processing is for legal claims. You also have an absolute right to object to processing for direct marketing; Wire does not currently conduct direct marketing.
• Withdraw consent — where we rely on consent, withdraw it at any time without affecting prior lawful processing (Art. 7(3)).
• Complain — lodge a complaint with a supervisory authority, in particular in your Member State of residence, place of work, or place of the alleged infringement (Art. 77), or with the UK Information Commissioner’s Office if the UK GDPR applies.

Send a request to privacy@wire-brief.com with “GDPR Request” in the subject line. Describe the right you wish to exercise and provide enough information for us to locate data we hold — typically your email address if you have written to us, and, if relevant, the approximate time you used the Service. Because we do not operate accounts, we may not be able to connect a browsing session to you without that information.

We will respond without undue delay and in any event within one month, extendable by two further months for complex or numerous requests, in which case we will tell you. We may ask for additional information reasonably necessary to verify that you are the data subject. We will not charge a fee unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse, as Article 12 permits.

Personal data are processed in the United States. Where we transfer personal data out of the EEA, the United Kingdom, or Switzerland to a country that has not been the subject of an adequacy decision, we implement appropriate safeguards, which may include the European Commission’s Standard Contractual Clauses (and the UK international data transfer addendum where required), together with any supplementary measures we assess as necessary. You may request information about the relevant safeguards from privacy@wire-brief.com, subject to redaction of confidential terms.

Your browser’s requests to third-party font or image hosts may independently result in a transfer of technical data to those hosts. Those transfers are governed by the third party’s own role (often as an independent controller) and legal mechanisms.

Recipients include our hosting and content-delivery provider, professional advisers, and authorities as described in the Privacy Policy. We impose contractual data-processing terms on processors who process personal data on our behalf, including the obligations in GDPR Article 28 where that Article applies.

We keep personal data only as long as necessary for the purposes collected, including the security and legal-claims periods described in the Privacy Policy. Correspondence is kept for the handling of the request and a reasonable archive period. Cookie preferences live on your device until you delete them.

The brief consists of news reporting and aggregation. Processing of personal data that appears in source reporting (for example, the name of a public official in a headline) is carried out for journalistic purposes. Where applicable, Member State implementations of GDPR Article 85, and corresponding UK provisions for journalistic purposes, may modify certain GDPR chapters as they apply to that content. Those modifications, where they exist, do not diminish the rights described in this notice as they apply to personal data we hold about you as a reader of the Service.

You may complain to your local supervisory authority. In the United Kingdom, that is the Information Commissioner’s Office (https://ico.org.uk). In the EEA, a list of authorities is published by the European Data Protection Board. You may also seek a judicial remedy. We would appreciate the chance to address your concern first at privacy@wire-brief.com.